On February 3, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a determination pursuant to sections 1(a)(ii), 1(b), and 5 of Executive Order 14071 and a determination pursuant to section 1(a)(ii) of Executive Order 14071 (“Determinations”) to implement the price cap policy for Russian petroleum products, building on earlier determinations related to Russian crude oil. OFAC also issued an updated guidance document relating to the price cap policy for Russian crude oil and petroleum…
On February 9, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 23, “Authorizing Transactions Related to Earthquake Relief Efforts in Syria.” General License 23 authorizes transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations (“SySR”) through 12:01 p.m. eastern daylight time, August 8, 2023. General License 23 does not authorize importation of petroleum or petroleum products of…
On January 17, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended (i) certain Russia-related General Licenses (“GLs”) and (ii) four Russia-related Frequently Asked Questions (“FAQs”). Amended General Licenses Amended GLs include the following: GL 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials,” replaces and supersedes GL 6B (see previous blog post here)…
On December 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued “Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin” to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (“Petroleum Products Guidance”). The petroleum products ban builds on a similar ban related to maritime transportation of Russian-origin crude oil that…